Jonathan DiFraia, a Pennsylvania state prisoner receiving Suboxone as part of a Medication Assisted Treatment program for opioid addiction, was removed from the program after prison guards twice found him with contraband and accused him of diverting his medication to other inmates. Dr. Timothy Kross gradually tapered DiFraia's doses over seven days rather than cutting him off cold turkey, but DiFraia still suffered withdrawal symptoms and mental health issues, leaving him scarred from picking at his arms.
Judge Stephanos Bibas, writing for the three-judge panel, emphasized that the Eighth Amendment requires both wrongful conduct and "a blameworthy mind," explaining that "deliberate indifference requires more than just making the wrong judgment call or failing to prevent harm." The court found no evidence that prison officials intended to harm DiFraia or acted with deliberate indifference, noting that the doctor's decision to taper rather than abruptly stop medication showed good faith medical judgment.
The case originated when DiFraia filed a pro se complaint in the Middle District of Pennsylvania before Judge Jennifer Wilson, alleging violations of the Eighth Amendment, ADA, and state tort law after being denied reinstatement to the Suboxone program. The district court dismissed all claims, relying on circuit precedent for the negligence claim that has since been abrogated by the Supreme Court's recent decision in Berk v. Choy.
The Third Circuit's ruling reinforces that prisoners cannot challenge good-faith medical decisions through constitutional claims, even when those decisions result in suffering. The court vacated only the negligence claim dismissal and remanded for further consideration, while affirming dismissal of the federal constitutional claims. The decision could impact how courts evaluate prisoner medical care disputes involving addiction treatment programs.